Real-Life Audit Findings Related to KPI Gaps



Real-Life Audit Findings Related to KPI Gaps

Published on 10/12/2025

Real-Life Audit Findings Related to KPI Gaps

In the pharmaceutical and biologics industries, adherence to established guidelines and standards is crucial for ensuring product quality and compliance. This requirement necessitates an understanding of the validation lifecycle, which includes key components such as process design, qualification, performance qualification (PPQ), continuous process verification (CPV), and revalidation. This article serves as a comprehensive guide for QA, QC, validation, and regulatory teams focusing on the implications of ISO 14644-1 cleanroom standards in the context of validation metrics and Key Performance Indicators (KPIs).

Step 1: User Requirement Specification (URS) & Risk Assessment

The foundation of any validation process begins with the User Requirement Specification (URS), which outlines all necessary requirements the process must fulfill. The URS should incorporate all relevant parameters for cleanroom environments, including the requirements dictated by ISO 14644-1 cleanroom standards. A comprehensive URS ensures that all aspects of the manufacturing process are addressed, primarily focusing on quality, regulatory compliance, and user expectations.

Risk assessment is a crucial component that follows the drafting

of the URS. It helps identify potential hazards that could impact product quality or patient safety. Effective risk management follows the principles outlined in ICH Q9, which emphasizes a systematic approach to identifying, evaluating, and controlling risks throughout the lifecycle of a product. A fundamental risk assessment strategy includes:

  • Identifying risks: Determine the potential failure modes and their causes.
  • Analyzing risks: Evaluate the potential impact and frequency of each risk to prioritize them for mitigation.
  • Controlling risks: Implement mitigation strategies and establish monitoring procedures.

Your risk assessment should also consider the varying cleanroom classifications as delineated in ISO 14644-1. For instance, Class 5 cleanrooms allow for a maximum of 3,520 particles per cubic meter, while Class 7 allows for up to 352,000 particles. Understanding these classifications is essential when defining acceptance criteria for environmental monitoring.

Step 2: Protocol Design

The design of the validation protocol is crucial for detailed execution and compliance with regulatory expectations. This document will guide validation activities and ensure they align with establishment requirements, meaning compliance with ISO 14644-1 cleanroom standards as well as guidelines from agencies such as the FDA and EMA.

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The protocol should include the following sections:

  • Objective: Clearly define the goal of the validation study.
  • Scope: Describe the boundaries, including cleanroom classifications and operations to be validated.
  • Test Methodology: Specify the methods to be employed for cleanroom monitoring, such as microbiological assessments, particulate counting, and temperature and humidity monitoring.
  • Acceptance Criteria: Define the criteria for passing validation tests, referencing ISO 14644-1 standards where appropriate. Implementing scientifically justified thresholds based on industry standards enhances compliance and accuracy.

After drafting the protocol, it must undergo a thorough review process involving all stakeholders. This collaborative approach ensures that all aspects and perspectives of the validation plan are considered, reducing the risk of oversights.

Step 3: Qualification Activities

The qualification phase involves a series of activities designed to confirm that the systems and processes operate according to the specifications defined in the URS. This typically includes three main components: Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).

Installation Qualification (IQ) verifies that all systems are installed correctly according to the manufacturer’s specifications. Document all installation steps and verify that all critical components meet the agreed-upon specifications.

Operational Qualification (OQ) assesses whether the system performs reliably under all anticipated operating conditions. This phase should include testing of all controls and alarm systems to ensure they function as intended within the defined cleanroom environment. Throughout this validation phase, environmental monitoring should validate sustained compliance with the various particulate and microbial limits set forth by ISO 14644-1.

Performance Qualification (PQ) evaluates the final validation of the system under real-world operating conditions and verifies that the process produces product consistently of the intended quality. This phase often involves full-scale production runs and assessments against the acceptance criteria documented in the protocol.

Step 4: Performance Qualification (PPQ)

Performance Qualification (PPQ), often regarded as the final validation confirming process capability, is the crucial step that formally establishes the process design’s efficacy in producing a consistent product. In the PPQ phase, documents about the product characteristics, key processing parameters, and cleanroom environmental monitoring need to be reviewed and align with the acceptance criteria.

During the PPQ, a minimum of three consecutive production batches should be produced under the established parameters to demonstrate consistent quality. It is important to document all findings meticulously, focusing on areas such as yield rates, variability in active pharmaceutical ingredient (API) concentrations, and microbial excursion incidents during the manufacturing runs. Statistical methods should be used for data evaluation to demonstrate compliance with the acceptance criteria, analyzing results in terms of means, ranges, and standard deviations.

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Each step of the PPQ must strictly follow the principles set forth in the governing documents such as FDA process validation guidance and ICH Q8–Q10. Special consideration must also be given to any deviations. It is essential to conduct thorough root cause analysis and implement corrective actions that not only rectify the immediate issue but also prevent reoccurrence.

Step 5: Continuous Process Verification (CPV)

Once initial validation activities are completed, Continuous Process Verification (CPV) becomes vital. CPV leverages ongoing monitoring of critical process parameters to ensure the continued compliance of both the process and product quality. This stage emphasizes the transition from process validation to ongoing quality assurance utilizing statistical and analytical tools.

One of the critical aspects of CPV involves establishing and regularly updating control charts. Control charts can identify trends in particulate counts, microbial levels, and environmental conditions, facilitating real-time decisions about process adjustments before they lead to product quality issues. In accordance with regulatory expectations, the findings from CPV should be documented, and integrated feedback loops should be established to ensure that process enhancements inform future batches.

It is also recommended that validation teams employ validation software for pharma purposes as a means to streamline the data management and documentation processes associated with CPV. Such software can automate data collection and analysis, providing real-time insights into the process performance while assuring compliance with regulatory guidelines.

Step 6: Revalidation

Revalidation is a critical phase that must be factored into the overall validation lifecycle plan. It is essential to conduct revalidation activities at prescribed intervals or when changes to the process, facilities, or equipment occur. According to FDA and EMA guidelines, establishing a clear revalidation strategy is indispensable for industries maintaining compliance due to its influence on product quality, regulatory adherence, and risk mitigation.

Common triggers for revalidation include:

  • Changes to equipment or process that may affect product quality.
  • Annual reviews of the validation lifecycle, acknowledging any deviations and corrective actions.
  • Modifications in environmental control systems or cleanroom classifications as outlined under EMA guidance.
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The revalidation effort should begin with a review of previous validation studies and environmental monitoring results. Utilizing statistical analysis, deviations found during CPV can be rationally categorized to facilitate comprehensive revalidation processes. Documentation of revalidation efforts is critical, ensuring transparency and rigor consistent with the practices established in ICH Q10, emphasizing that proactive approaches to validation lifecycle management prevent potential failures.

Conclusion

The validation lifecycle in pharmaceutical processes is complex and multifaceted, heavily governed by regulatory guidelines such as ISO 14644-1 cleanroom standards. Each phase of validation serves to ensure compliance with established quality expectations, and any gaps in adherence can lead to significant regulatory risks and product quality inconsistencies.

By following these structured steps and employing relevant methodologies, organizations can maintain robust validation and monitoring practices that align with industry regulations. Continuous improvement, bolstered by effective documentation, risk management, and revalidation strategies, is the pathway to sustained product quality in the pharmaceutical and biologics industries.